“limited scrutiny”

Assessment ProceduresSection 143(3)Section 143(3)2,866 judgments

The decision most relied on for limited scrutiny is Vipan Khanna v. CIT (255 ITR 220), cited in 140 judgments on BharatTax.

Leading authorities on limited scrutiny

Vipan Khanna v. CIT

255 ITR 220 · 2002 · High Court

140

citing judgments

Assessment proceedings conclude and become final if a scrutiny notice under Section 143(2) is not served within the prescribed statutory period. This case also clarified the historical position that reassessment under Section 147/148 was restricted to issues for which reasons were recorded, a view superseded by Explanation 3 to Section 147.

Duggal & Co. v. CIT

220 ITR 456 · 1996 · High Court

citing judgments

An assessment order becomes erroneous and prejudicial to the revenue under Section 263 if the Assessing Officer fails to conduct a proper inquiry or investigation, even if the return appears prima facie correct. The Income-tax Officer has a duty to investigate and cannot remain passive.

Amal Kumar Ghosh v. Asstt. CIT

361 ITR 458 · 2014 · High Court

citing judgments

The selection of cases for scrutiny must be completed within the time prescribed by CBDT instructions. The department is bound by its own standards and cannot act with discrimination or selectively apply them.

PCIT v. Weilburger Coatings (India) (P.) Ltd.

155 Taxmann.com 580 · 2023 · High Court

citing judgments

Assessing officers cannot introduce issues for inquiry that were not part of the original limited scrutiny, without adhering to mandatory procedural requirements.

Balvinder Kumar v. PCIT

125 Taxmann.com 83 · 2021 · High Court

citing judgments

An Assessing Officer cannot travel beyond the scope of issues selected for limited scrutiny during the assessment proceedings.

PCIT v. Shark Mines and Minerals (P.) Ltd.

151 Taxmann.com 71 · 2023 · High Court

citing judgments

Revisionary powers under Section 263 cannot be invoked to find fault with an assessment order on an issue not covered by 'limited scrutiny' where the Assessing Officer could not have examined such an issue.

CIT v. Smt. Padmavathi

120 Taxmann.com 187 · 2020 · High Court

citing judgments

An assessment order cannot be held erroneous and prejudicial to revenue if the Assessing Officer (AO) could not have travelled beyond the issues forming the subject matter of 'limited scrutiny'. The Principal Commissioner of Income Tax (PCIT) cannot invoke Section 263 to set aside an assessment on grounds not forming part of the limited scrutiny.

Mahanagar Telephone Nigam Ltd. v. Chairman, Central Board of Direct Taxes and Another

246 ITR 173 · 2000 · High Court

citing judgments

An Assessing Officer can initiate reassessment proceedings under Section 147 even if a scrutiny notice under Section 143(2) was not issued within the prescribed time, provided the conditions for Section 147 are met. An intimation under Section 143(1)(a) does not preclude recourse to Section 147.

Judgments citing limited scrutiny

Bsst India Private Limited, Ghaziabad vs. Commissioner of Income-Tax (Appeals), Delhi

In the result, appeal is allowed

ITA 4448/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Dec 2025AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.4448/Del/2025 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Bsst India Private Limited, Commissioner Of Income Tax D-586, Govind Puram, Vs. (Appeals), Ghaziabad. National Faceless Appeal Centre, Pan No.Aafcb8294F (Nfac), Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 2(22)(e)Section 250

also been tendered for our consideration, challenging the fact that the Ld. AO could not have made this addition within the purview of “Limited Scrutiny”. The Ld. AR submitted that the additional ground may be taken up in case the assessee is not considered to be covered for relief under

Rohini Maruti Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1839/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT

Section 250Section 271(1)(c)Section 44ASection 54B

Under the facts and circumstances of the case and in law, the assessee's case was selected for limited scrutiny for the specific purpose of examining the issue "large deduction claimed u/s 54B, 54C, 54D, 54G and 54GA & Large Investment in property (AIR) as compared to total income". However ... Assessing Officer has travelled beyond the scope of limited scrutiny by reclassifying the nature of income and making an addition under the head "Business Income", which is contrary to the scope of enquiry permitted under the limited scrutiny guidelines. Hence addition is not sustainable. Accordingly, penalty cannot be levied

Tulsabai Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1838/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT

Section 250Section 271(1)(c)Section 44ASection 54B

Amol Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1837/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT

Section 250Section 271(1)(c)Section 44ASection 54B

DCIT-Circle 1(1), Pune, Swargate Pune vs. Ansec Human Resource Services Limited, Pune

In the result, the appeal of the Revenue is allowed for statistical purpose

ITA 1309/PUN/2025[2018-19]Status: DisposedITAT Pune17 Dec 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Smt. Deepa KhareFor Respondent: Shri A D Kulkarni

Section 142(1)Section 143(3)Section 80J

deduction u/s 80JJAA of the Income Tax Act, 1961 (the “Act”) of Rs.2,07,12,896/-. The case of the assessee was selected for limited scrutiny through CASS for verification of “deduction from total income under chapter VI-A”. During the assessment proceedings, on verification of Form No. 10DA uploaded

Kumarasamy Ramalingam, Erode vs. ITO, Ward-2(1), Erode

In the result, the appeal filed by the assessee is allowed and the Stay Application is dismissed

ITA 3240/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Dec 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.3240/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & S.A. No. 120Chny/2025 [In Ita No. 3240/Chny/2025] Kumarasamy Ramalingam, Vs. The Income Tax Officer, 133, Mullai Nagar, Old Bus Stand Ward 2(1), Road, Perundurai, Erode 638 052. Erode. [Pan: Ajnpr1672H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Bhupendran, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.09.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 5 Grounds Of Appeal, Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Shri S. Bhupendran, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 143(3)

individual, employed in Joint Directorate of Animal Husbandry. The assessee filed the return of income declaring a total income of ₹.11,44,300/-. Under Limited Scrutiny, the Assessing Officer issued notice under sections 143(2) and 142(1) of the Income Tax Act, 1961 [“Act” in short], in response

K1434 Senjerimalaiyadipalayam Primary Agricultural Co Opcredit Society, Coimbatore vs. The Income Tax Officer, Non Corp Ward 4(1), Coimbatore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2179/CHNY/2025[2016-2017]Status: DisposedITAT Chennai17 Dec 2025AY 2016-2017

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.2179/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 K1434 Senjerimalaiyadipalayam Vs. The Income Tax Officer, Primary Agricultural Co-Op. Credit Non Corporate Ward 4(1), Society, Malayadipalayam Post, Coimbatore. Sultanpet Via, Sulur Taluk, Coimbatore 641 669. [Pan:Aabak0950D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Karunanandham, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.02.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. We Find That This Appeal Is Filed With A Delay Of 462 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons.

For Appellant: Shri Karunanandham, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 143(1)Section 143(3)Section 80PSection 80P(2)(a)

assessee was processed under section 143(1) of the Income Tax Act, 1961 [“Act” in short]. Thereafter, the case was selected for limited scrutiny. After following due procedure, the Assessing Officer completed the assessment under section 143(3) of the Act dated 29.12.2018 inter alia, making various additions

Brawny Nivesh P.Ltd, New Delhi vs. ACIT, Central Circle-13, New Delhi

In the result, appeal of the assessee is partly allowed

ITA 571/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Mahavir Singh & Shri Brajesh Kumar Singh

Section 143Section 143(3)Section 3Section 47Section 56Section 56(2)(via)Section 56(2)(viia)

assessee on24/09/2015 vide acknowledgement No. 815747901240915 showing total income ofRs.7,587/-. The case was selected for scrutiny assessment through CASS under the category "Limited Scrutiny" and accordingly notice u/s.143 (2) of the I.T. Act, 1961 was issued on 21/04/2016 and duly served upon the assessee. According to the AO, during ... entire business transactions including trading and investments in shares are bogus/non-genuine. Therefore, such finding, being broad, is held falling within the following parameters of limited scrutiny: i. Low income in comparison to very high investments. ii. Low income in comparison to high loans/advances/investment in shares ITA No.-571/Del/2019 Brawny

Baby Chatterjee, Ranchi vs. Income Tax Officer, Ward-1(3), Ranchi

In the result, this appeal of assessee is partly allowed

ITA 241/RAN/2023[2017-18]Status: DisposedITAT Ranchi16 Dec 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Baby Chatterjee, I.T.O., 2A/2B, Krishna Enclave, North Office Ward 1(3), Vs. Para, Doranda, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Anppc 8818 A Appellant/ Assessee Respondent/ Revenue

Section 142(1)Section 272A(1)(d)Section 274Section 69A

summary manner without rightly appreciating the facts and grounds of appeal. 2. For that the case of the assessee was selected for limited scrutiny on the reason "cash deposited during the year." The AO was not justified in travelling beyond this limited issue and making addition of entire credits/ deposits ... income from other sources (interest)' for the assessment year under consideration and declared total income at ₹ 4,16,400/- . The case was selected for limited scrutiny through CASS selection on the ground of "cash deposit during the year". Accordingly, statutory notices were issued from time to time. However, no compliance

Shri Kamleshkumar Vallabhbhai Chanchdia, Village Sardhar, Dist. Rajkot vs. The ITO-Ward-2(1)(2), Rajkot

In the result, appeal of the assessee, is allowed for statistical purpose

ITA 156/RJT/2021[2016-17]Status: DisposedITAT Rajkot16 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri S. N. Divetia, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

income was processed u/s. 143(1) of the Income Tax Act, 1961 (hereinafter 'the Act'). The case was selected for scrutiny through CASS in LIMITED scrutiny with a reason of Whether revision of return is justified". Accordingly, a notice u/s. 143(2) of the Act was issued

Suvas Hitendrabhai Barot, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1401/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri Kamal Deep Singh, Sr. DR

Section 115BSection 142(1)Section 234ASection 249(3)Section 271ASection 69

before the hearing of the appeal.” 3. The brief facts of the case are that the assessee, an individual, was subjected to limited scrutiny for the Assessment Year 2018-19 on the issue of substantial cash payments towards credit card expenses as reported under Statement of Financial Transaction

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Kay Bouvet Engineering Limited, Satara

In the result, both the appeals filed by the Revenue and both the COs filed by the assessee are dismissed

ITA 1392/PUN/2025[2019-20]Status: DisposedITAT Pune16 Dec 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Ashwani Kumar &For Respondent: S/Shri Amol Khairnar CIT-DR and Manish M. Mehta

Section 131Section 133ASection 143(1)(a)Section 143(3)Section 148

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) on 13.11.2019. Subsequently the case was selected for limited scrutiny through CASS for verification of ‘share premium’. The Assessing Officer passed an order u/s 143(3) of the Act on 05.01.2021 accepting the returned income. 3. Subsequently a survey

Dy Commissioner of Income Tax, Satara vs. Kay Bouvet Engineering Limited, Satara

ITA 1374/PUN/2025[2018-19]Status: DisposedITAT Pune16 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Respondent: Shri Ashwani Kumar &

Section 131Section 133ASection 143(1)(a)Section 143(3)Section 148

Income Tax Act, 1961 (hereinafter referred to as 'the Act') on 13.11.2019. Subsequently the case was selected for limited scrutiny through CASS for verification of 'share premium'. The Assessing Officer passed an order u/s 143(3) of the Act on 05.01.2021 accepting the returned income. 3. Subsequently a survey

Bhadravathi Ramalingasetty Manjunath Setty, Bhadravathi vs. ITO Ward-1 Tps, Shimoga

In the result, appeal filed by the assessee is allowed

ITA 1459/BANG/2025[2018-19]Status: DisposedITAT Bangalore16 Dec 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri Sachin S Rao, A.RFor Respondent: Sri Balusamy N., D.R

Section 139Section 139(4)Section 139(9)Section 143(2)Section 143(3)Section 250Section 271BSection 44A

income u/s 139(9) of the Act on Bhadravathi Ramalingasetty Manjunath Setty, Shivamogga Page 4 of 12 10.5.2019. The case was thereafter selected for limited scrutiny i.e. “bonus or commission to employees” under CASS and accordingly notices u/s 143(2) as well as 142(1) of the Act were issued

Ketan Himatlal Mehta, Mumbai, Maharashtra vs. NFAC, Not Applicable

Appeal is partly allowed

ITA 2499/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 Dec 2025AY 2020-21

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Pravin Salunkhe

Section 143(3)Section 144BSection 32MSection 56(2)(x)

filed return of income on 25.06.2018 declaring total income at Rs.8,18,890/-. The return of income filed by the assessee was selected for limited scrutiny for verification of the fact that purchase value of the property recorded in the sale consideration was less than the value

Shri Naval Kishore Singh, Jammu vs. Deputy Commissioner of Income Tax Circle-1, Jammu

In the result, the ground of appeal No

ITA 376/ASR/2023[2014-15]Status: DisposedITAT Amritsar15 Dec 2025AY 2014-15

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Joginder Singh, C. A

Section 144Section 250Section 44A

profit of 56.59 lakhs on a total turnover of Rs. 4.50 crores for the year under appeal , and the case was picked for limited scrutiny and on examination of the audited balance sheet as at 31st March, 2014, closing capital was reflected at Rs.2.88 crores (as observed

Daljit Kaur, Haryana vs. ITO, Ward-1, Sirsa, Haryana

In the result, the appeal of the assessee is dismissed

ITA 697/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Dec 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual Mode)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 56(2)(viii)Section 57

income from other sources of Rs.2,39,397/-, with the total income rounded off at Rs.2,29,400/-. The case was selected for limited scrutiny under CASS, and statutory notices were issued to verify the correctness of the particulars declared. During examination of the return, it was noticed that

Aadarsh Surana, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18

For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT

Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

Circle-1(1), Chennai, is bad in law, void ab initio, and without jurisdiction, inasmuch as the Assessing Officer has converted the case from 'limited scrutiny' to 'complete scrutiny' without obtaining the mandatory prior approval of the Principal Commissioner of Income Tax (PCIT) as required under the relevant CBDT Instructions ... Rs.1,71,42,113/-, income from house property of Rs.7,000/– and income from other sources of Rs.14,826/-. The case was selected for limited scrutiny assessment for verification of the following issues: - i. Expenses incurred for earning exempt income ii. Share capital/capital 6. Consequently, notice u/s.143

Shree Jagadguru Mouneshwar Pattin Sahakari Sangh Niyamit Kerur, Bagalkot vs. Income Tax Officer, Ward-1, Bagalkot

In the result the appeal filed by the assessee is allowed

ITA 1623/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi

Section 143(3)Section 144BSection 56Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)

case, the return of income was e-filed on 30.03.2021 declaring total income at Rs. Nil. The case of the assessee was selected for LIMITED scrutiny under Page 1 of 10 CASS for the reason “High liabilities/low income in-comparison to high loans/advances/investments and to verify the deduction u/s chapter

August Jewellery Private Limited, Bengaluru vs. D.C.I.T., Circle 1(1)(1), Bengaluru

ITA 1457/BANG/2025[2022-2023]Status: DisposedITAT Bangalore15 Dec 2025AY 2022-2023

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Miraj Shah, ARFor Respondent: Shri. Shivanand H Kalakeri, CIT(DR)(ITAT), Bangalore

Section 143(3)Section 270ASection 271ASection 68

loss of (-)Rs.97,64,90,311. The return was processed under section 143(1) of the Act and case was selected for scrutiny under limited scrutiny through CASS and subsequently, others statutory notices were issued to the assessee. During the course of scrutiny proceedings, the AO made following additions